Interview with GRATA International Partner Assel Ilyassova on Tax law
1) Can you tell us about your journey to becoming a partner in the GRATA law firm?
Prior to joining GRATA Law Firm, I worked for the tax authorities of Kazakhstan, where I provided legal support for tax inspectors and defended the interests of the tax authority in court. At the firm, I started as a senior lawyer. Since the tax practice had just been established and was still developing, we had to start everything from scratch. We colleagues actively learned from each other and supported one another, making it a challenging yet interesting period.
After successfully completing a Master's program and obtaining my Master’s degree, I was tasked with managing the Tax Law Department, which later expanded to include the Customs practice. This leadership role allowed me to develop skills in management and strategic planning, which proved to be incredibly interesting and enriched my professional life. My performance and contributions to the firm’s growth led to me being honoured with a partnership.
2) What initially drew you to specialise in tax law?
To be honest, I became a tax lawyer somewhat by chance. After graduation, while searching for a job, I was informed that the legal department of a tax authority was seeking a lawyer. I submitted my CV, completed an internship, and was subsequently hired. This decision ultimately shaped my specialisation and career path.
3) What are the most common concerns or issues clients bring to you regarding tax law?
Foreign entities planning to do business in Kazakhstan often approach us with questions concerning the tax regime and tax planning. They seek to understand how to optimally structure their business in compliance with local legislative requirements, including tax laws.
The second most common request involves representing and defending the interests of Kazakh entities in disputes with tax authorities. In such cases, we assist clients in developing a defence strategy, preparing necessary documents, and representing their interests before tax and judicial authorities.
Consequently, our work encompasses both advisory and defence functions, providing comprehensive support to our clients.
4) How has the field of tax law evolved since you started practising and what changes do you foresee in the next 5-10 years?
Tax law in Kazakhstan is one of the most dynamically developing areas of law. Since the country's independence, five main tax acts have been adopted: the laws in force from 1991 to 1995 and from 1995 to 2001; and codes from 2002 to 2008, from 2009 to 2017, and from 2018 to the present. In the last seven years alone, for example, 40 acts have been adopted to amend and supplement the current Tax Code. Starting in 2025, a new Tax Code is expected to be introduced, marking the sixth major tax law, the draft of which was recently published.
It should be noted that Kazakhstan’s tax system has always aimed to simplify administration, including through digitalization. Significant progress has been made in this direction, including the introduction of numerous electronic services such as the taxpayer’s cabinet, virtual warehouse, and electronic invoices.
However, there has been a problem with law enforcement by the tax authorities. With the introduction of the Administrative Procedure Code in 2021 and the establishment of a separate panel for administrative cases in the Supreme Court, which has jurisdiction over cases between private entities and state authorities, including tax disputes, there have been positive changes. According to the Supreme Court of Kazakhstan, currently about half of the tax disputes are decided in favour of taxpayers, a significant shift from previous practices.
Additionally, Kazakhstan joined the Multilateral Instrument (MLI), introducing additional requirements for the application of tax treaties to prevent their abuse.
A new draft Tax Code was recently announced, which will continue the trend towards the digitalization of the tax system. Notably, tax audits will now be conducted remotely through the taxpayer’s office, and tax administration will be further simplified, with reductions in tax reporting requirements. An important change will also include the differentiation of income tax rates for business: the general rate will be set at 20%, with 25% for the banking sector and gambling business, 10% for the manufacturing industry, and an effective rate of 3% for agricultural producers.
5) What skills or qualities do you believe are essential for success in this field? What advice would you give to law students or young lawyers aspiring to specialise in tax law?
To succeed in any activity, it is essential to first and foremost love what you do. In my opinion, tax law is one of the most complex yet fascinating areas of law. If you enjoy your work, you are already halfway to success. Another key quality is professional integrity, which includes, among other things, a conscientious attitude toward one's work. For a lawyer, this is one of the most crucial qualities. Lastly, success is unattainable without hard work and discipline.
6) How is technology changing the way tax law is practised and how do you prepare for and adapt to these trends?
As I have previously mentioned, the Government of Kazakhstan is actively continuing to digitise public services. This includes tax administration and control. In my view, such modernization significantly simplifies business operations, making processes more transparent and accessible. Electronic tax declarations, online business registration, and the ability to track the status of one's tax obligations in real time—all these advancements reduce the time spent on bureaucratic procedures and minimise the human factor, which ultimately contributes to the development of the entrepreneurial environment in the country. Additionally, even court proceedings are now conducted electronically, with hearings held remotely online.
